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Somers v. Digital Realty Trust, 15-17352 (9th Cir. March 8, 2017)

Articles Discussing Case:

Circuit Split Over Protection Afforded By Dodd-Frank Whistleblower Provision Widens

Jackson Lewis P.C. • March 17, 2017
In Somers v. Digital Realty Trust, 15-17352 (9th Cir. March 8, 2017), a split Ninth Circuit Court of Appeals widened an existing circuit court split by ruling that Section 21F of the Dodd-Frank Act (“DFA”) protects individuals who make internal disclosures as well as those who make disclosures to the Securities and Exchange Commission (“SEC”).

9th Circuit Decision Protects Internal Whistleblowing Under Dodd-Frank

XpertHR • March 17, 2017
The 9th Circuit Court of Appeals has issued a decision that individuals who complain internally, but who do not make an external complaint to the Securities and Exchange Commission (SEC), are protected whistleblowers under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank). In Somers v. Digital Realty Trust Inc., the 9th Circuit deepens the existing circuit split between the 2nd and 5th Circuit Courts of Appeals regarding the definition of whistleblower under Dodd-Frank.